## Facts

- Welford Wigglesworth, Jr. was a member of Teamsters Local Union No. 592; William A. Hodson was the Local’s president and presiding officer at membership meetings.
- Wigglesworth and Hodson had a long-running dispute that included Wigglesworth’s prior challenge to a union election and a Department of Labor-supervised rerun election.
- Wigglesworth sued under LMRDA § 102 (29 U.S.C. § 412), alleging Title I violations at Local membership meetings on September 8, 1974 and October 13, 1974.
- Wigglesworth alleged Hodson curtailed his ability to speak at meetings, refused requests for information about the Local’s financial affairs, and refused a request to inform members of their rights under the LMRDA.
- At the September 8 meeting, a dues increase was a key agenda item; Wigglesworth spoke against it and testified he was cut short and ruled out of order.
- After trial, the district court entered judgment for Wigglesworth, granting injunctive relief and awarding $13,000 compensatory damages, $19,000 attorney’s fees, and $2,797.86 in costs and expenses.
- The Local and Hodson appealed the merits judgment to the Fourth Circuit.

## Issues

1. Whether Hodson’s conduct at union membership meetings infringed Wigglesworth’s LMRDA Title I rights, including rights to speak and participate in union meetings and to obtain relevant union financial information.
2. Whether the district court’s injunctive relief and monetary awards (compensatory damages, attorney’s fees, and costs) were supported by the evidence and authorized under LMRDA § 102.

## Decision

- The Fourth Circuit largely affirmed the district court’s judgment for Wigglesworth.
- The court upheld findings that defendants infringed Title I rights through meeting rulings and conduct that curtailed dissenting speech and participation.
- The court accepted that defendants’ refusal to provide requested financial information and refusal to communicate members’ statutory rights supported relief under § 102.
- The court upheld substantial equitable and monetary relief, including compensatory damages and attorney’s fees, based on the proven interference with protected rights.

## Legal Principles

- LMRDA § 102 authorizes a civil action when a union member’s Title I rights are infringed by a union or its officers.
- Title I protects a member’s right to express views and participate in union meetings, subject to reasonable meeting rules; meeting control may not be used as a pretext to suppress dissent.
- Union action that effectively chills protected speech or participation at meetings can constitute an actionable Title I violation.
- Courts may grant injunctive relief to prevent ongoing or future violations of Title I rights.
- Where infringement is proven, courts may award compensatory damages and attorney’s fees as part of appropriate relief under § 102.

## Conclusion

The Fourth Circuit held that a union local and its president violated a member’s LMRDA Title I rights by restricting his meeting speech and participation and by refusing related informational requests, and it largely affirmed injunctive relief and significant monetary awards to remedy the violations.


Wigglesworth v. Teamsters Loc. Union No. 592, 552 F.2d 1027 (4th Cir. 1977)